Hazari v. County of Santa Clara

Background

Cyrus Hazari moved to disqualify the judge assigned to his case. He first filed the motion on April 10, 2025, but refiled it on April 13 after the court identified a filing error. The court decided the motion without a hearing and did not require a response from the defendants.

The motion followed two earlier rulings. On March 10, 2025, the court denied Hazari’s request for relief by accommodation for disabilities. On March 24, 2025, the court denied Hazari’s motion to set aside that ruling. In those rulings, the court relied in part on Hazari’s rapid and lengthy filings as evidence that his documented disabilities did not prevent him from prosecuting the case.

Legal standard

The court considered the disqualification standards in 28 U.S.C. §§ 144 and 455. Section 144 addresses a judge’s alleged personal bias or prejudice. Section 455 requires disqualification when a judge’s impartiality might reasonably be questioned, including when the judge has personal bias or prejudice concerning a party or personal knowledge of disputed facts.

The court applied an objective test: whether a reasonable person who knew all the facts would conclude that the judge’s impartiality might reasonably be questioned. The court also stated that a judge is presumed impartial and that the party seeking disqualification bears a substantial burden to show bias.

Discussion and ruling

Hazari argued that a judge may not preside over a case involving a disabled litigant, disability-related questions, or treaty and human-rights issues while an independent investigation was pending. He based the request on his disagreement with the court’s denial of his request to further stay the case because of what he described as serious illness and substantial incapacity.

The court found that Hazari had not shown that disqualification was warranted under either Section 144 or Section 455. It determined that the motion relied on disagreement with the court’s prior ruling, and explained that judicial rulings alone almost never provide a valid basis for a bias or partiality motion. The court also noted that, after being told about the filing error, Hazari submitted another 125-page brief within two days, which the court viewed as further evidence that his disability did not interfere with his ability to prosecute the case.

The court DENIED Hazari’s motion for disqualification. It separately found that both filings violated page limits under the Civil Local Rules and the court’s standing order, warned that future noncompliant papers would be stricken, and stated that it would consider up to 25 pages of the relevant portion of the first filing if that filing was intended to respond to the defendants’ motion to dismiss. The court also stated that footnotes on those pages were stricken.